Introduction
The coal mining industry is a key source of
methane, a powerful greenhouse gas (GHG). In
the United States, coal mines contribute about
10 percent of anthropogenic methane emissions,
while worldwide, coal mines are estimated to
produce more than 912 metric tons of carbon
dioxide equivalent (CChe) of methane emissions
by 2030.1 Technologies for capturing and utilizing
a significant portion of coal mine methane
emissions are readily available.
Projects that capture and use coal mine methane
(CMM), rather than venting it into the
atmosphere, can earn GHG emissions reduction
or offset credits created through compliance and
voluntary programs in the United States. Some
of these programs are driven by mandated caps
on GHGs, while others operate in the voluntary
carbon market.
As of 2020, two compliance and three voluntary
GHG emissions trading programs operate in the
United States; of these, four allow CMM
emissions reduction projects (see Exhibit 1). This
document summarizes these GHG programs and
compares their key features as they pertain to
CMM emissions reduction projects (see Exhibit 2).
For example, some programs accept abandoned
mine methane (AMM) recovered from abandoned
coal mines or surface mine methane (SMM)
recovered from surface coal mines, while others
only accept CMM or ventilation air methane
(VAM) recovered from active underground mines.
The remainder of this document provides
additional information about these four programs.
Disclaimer: U.S. EPA is providing this overview of the programs for informational purposes
only and does not endorse or support any specific program.
1 U.S. EPA. 2019. Global Non-C02 Greenhouse Gas Emission Projections & Mitigation Potential: 2015-2050. EPA 430-R-19-010. Available:
https://www.epa.eov/global-mitigation-non-co2-ereerihouse-gases/global-non-co2-greenhouse-gas-emission-proiections.
www.epa.gov/crnop
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About the Coaibed Methane Outreach Program
Since 1994, the Environmental Protection Agency's (EPA's)
Coaibed Methane Outreach Program (CMOP) has worked
cooperatively with the coal mining industry in the United
States-and other major coal-producing countries-to
reduce CMM emissions.
Learn more at: www.epa.gov/cmop
Contact CMOP at:
www.epa.gov/cmop/forms/contact-
us-about-coal-methane-outreach-
U.S. EPA: f' ft
Coaibed Methane!
Exhibit 1. Key U.S. GHG Emissions Trading Programs
Program
Allows CMM
Projects
Compliance Programs
California Compliance Offset
•J
Program (COP)
Regional Greenhouse Gas Initiative

(RGGI)

Voluntary Programs
Climate Action Reserve (CAR)
•J
Verra's Verified Carbon Standard

(VCS)
American Carbon Registry (ACR)

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Exhibit 2. Comparison of CMM Project-Eligibility Requirements for U.S. GHG
Emissions Trading Programs
GHG
Program:
COP
CAR
vcs
ACR
Type
Compliance
Voluntary
Voluntary
Voluntary
Protocol issue
date
April 2014
October 2009
(updated October
2012)
CMM - November 2007
(updated February 2014)
SMM revisions - March 2009
AMM revisions - July 2010
September 2019
Mine methane
eligibility
CMM, AMM,
SMM, VAM
CMM, VAM
CMM, AMM, SMM, VAM
CMM, AMM,
SMM, VAM
Project end-
use types
Boilers, heaters,
electricity, flares,
thermal oxidizers
Boilers, heaters,
electricity, flares,
thermal oxidizers
Boilers, heaters, pipelines,
electricity, flares, thermal
oxidizers
Boilers, heaters,
pipelines,
electricity, flares,
thermal oxidizers
Location
United States
United States
Worldwide
North America
Project
validation date
Projects must be
validated within
one year of project
start date
Projects must be
validated within
six months of
project start date
Under Standard v4.0,
validation must be completed
within two years of project
start date
Under
Standard v6.0,
validation must be
completed within
two years of
project start date
Additionality3
Performance
standard
Performance
standard
Project-based standard
Performance
standard
a. Additionality refers to the eligibility requirement that offset credits must be in addition to
what would have happened in the absence of the project, and that reductions are above
and beyond business-as-usual. A performance standard establishes a threshold for
technologies or processes that must be met or exceeded in order for a project to be
additional. A project-based standard evaluates projects on a case-by-case basis and allows
for the use of different additionality tests (e.g., financial, technological, common practice),
depending on the type of project.2
GHG Emissions Trading Programs: Compliance
The COP is the only compliance program in the United States that allows CMM projects to
be eligible for offset credits. The other U.S. compliance program, the RGGI, does not allow
emissions reductions from CMM projects to receive credit.
COP
Program Background
The California Air Resources Board (CARB) is the state agency responsible for maintaining
healthy air quality and protecting the public from the harmful effects of air pollution. Since
2011, CARB has operated the COP as part of the state's broader Cap-and-Trade program.
The state's largest emitters are required to meet GHG emissions caps by surrendering
compliance instruments (i.e., allowances or offsets). The COP allows these covered entities
2 Partnership for Market Readiness. 2015. Overview of Carbon Offset Programs: Similarities and Differences. Available:
https://www.thepmr.org/svstem/files/documents/PMR%20Technical%20Note%206 Offsets O.pdf.
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to purchase and trade offsets from projects
anywhere in the United States to meet up to
eight percent (four percent beginning in 2021) of
their compliance obligation. CMM projects are one
of six project types with a protocol that has been
approved to generate offsets under the COP. The
other project types are U.S. forest, urban forest,
livestock, ozone-depleting substances, and rice
cultivation.
When the COP began, it allowed qualified existing
offset projects developed under voluntary
programs to transition offsets to the COP. Only
offsets achieved through 2014 were eligible to transition to the COP. Seven CMM projects
transitioned offsets to the COP, for a total of 2.88 million offsets.3
Mine Methane Protocol
CARB's current CMM protocol is the Mine Methane Capture (MMC) Protocol, adopted on
April 25, 2014. This protocol allows CMM projects at active underground mines, surface
mines, and abandoned underground mines; as well as VAM projects at underground mines
(Exhibit 3).
The MMC Protocol uses a performance standard approach to assess additionality rather
than a project-based standard approach. A performance standard approach establishes a
threshold for technologies or processes that must be met or exceeded in order for a project
to be additional; while a project-based standard approach evaluates projects on a case-by-
case basis and allows the use of different additionality tests (e.g., financial, technological,
common practice), depending on the project type. In the MMC Protocol, the performance
standard test is satisfied if the project destroys VAM via any end-use management option,
destroys mine methane from an active underground mine via any end-use management
option (except pipeline injection), destroys mine methane from a surface mine via any end-
use management option, or destroys mine methane from an abandoned mine via any end-
use management option except pipeline injection (unless the pipeline project existed only
after the mine was abandoned). Pipeline injection of CMM from methane drainage systems
at active underground mines was considered business-as-usual by CARB and, therefore,
pipeline projects are ineligible to generate offsets under the MMC Protocol.
The MMC Protocol also requires that projects satisfy the Legal Requirement Test, which
confirms that a project's GHG emissions reductions would not have occurred due to federal,
state, or local regulations; or other legally binding mandates.
GHG Registries
For projects to be eligible, CARB requires that they be listed, reported, and verified through
an approved offset project registry (OPR). Since 2016, three voluntary GHG registries—
ACR, CAR, and VCS—are approved as offset project registries for the COP (see the
following section for more information about these registries). These programs issue
Registry Offset Credits (ROCs) once the registry approves the project. ROCs are then
converted to CARB Offset Credits (CARBOCs) by CARB for use in the cap-and-trade
program. One ROC is equal to one CARBOC, which is equal to 1 metric tonne of C02e. For
more information, visit: https://ww2.arb.ca.aov/.
Exhibit 3. Summary of MMC Projects under
CARB
ARB has issued offsets to 10 MMC projects under
the current protocol. As of June 2020, MMC
projects have been issued credits for 7.24 million
metric tons of CChe reductions in the COP
(including early action offsets), representing
four percent of the total compliance offset
credits issued by CARB.
3 State of California. 2020. CARB Offset Credit Issuance Table. Available:
https://ww3.arb.ca.gov/cc/capandtrade/offsets/issuance/issuance.htm.
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GHG Emissions Trading Programs: Voluntary
The purchase of voluntary offset credits is driven by companies wishing to offset their own
emissions for corporate social responsibility or pre-compliance reasons. Voluntary carbon
markets co-exist with compliance markets, which operate to manage market caps and GHG
emissions permits for regulated industries.
Climate Action Reserve (CAR)
Program Background
CAR is a nonprofit organization based in California that operates a voluntary offset program
and trading system. Launched in 2008, and most recently updated in 2019, it is the newest
voluntary offset program within the U.S. carbon market. The program establishes
standards to develop, quantify, and verify GHG emissions reduction projects for a variety of
project types in the United States and Mexico (Exhibit 4). The registry's standards are
outlined in project-specific protocols for various sectors, including forest, livestock, landfill,
urban forest, CMM, organic waste digestion, nitric acid production, ozone-depleting
substances, grasslands, nitrogen management, organic waste composting, and rice
cultivation.
Mine Methane Protocol
CAR's CMM Protocol was first issued in 2009; the
updated version, Coal Mine Methane Project
Protocol Version 1.1, was issued October 26, 2012.
This protocol allows CMM projects only at
underground mines, including gas drainage or VAM
projects. The CMM Protocol uses a performance
standard approach similar to CARB's protocol, in
which the performance standard test is satisfied if
the project destroys CMM from an active
underground mine through any end-use
management option (other than injection into a
natural gas pipeline) for offsite consumption, or destroys VAM through any end-use
management option. The protocol also requires that projects satisfy the Legal Requirement
Test, which ensures that a project's GHG emissions reductions would not have occurred
due to federal, state, or local regulations; or other legally binding mandates.
The COP and CAR are the only programs that do not include pipeline projects or CMM
projects outside the borders of the United States and its territories.
GHG Registry
CAR manages its own registry where it lists projects, collects project documents, facilitates
verification, and issues and retires offset credits for its projects. CAR's emissions reduction
unit is the CRT, where 1 CRT is equal to 1 metric tonne of C02e. For a list of emissions
reduction units by program, see Exhibit 5.
CAR became an approved OPR for the COP in 2012. For more information, visit:
https://www.climateactionreserve.org/.
Exhibit 4. Summary of Projects under CAR
Four CMM projects have been issued climate
reserve tonnes (CRTs) from the CAR; however,
all of these CRTs were transitioned to early
action offset credits for use in the COP. No CMM
projects are currently quantifying emissions
reductions under CAR's CMM Protocol.
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Exhibit 5. Emissions Reduction Units by Program
Program
Emissions Reduction Units
CAR
CRT. One CRT is equal to 1 metric tonne of C02e.
VCS
Voluntary carbon unit (VCU). One VCU is equal to 1 metric tonne of C02e.
ACR
Emission reduction ton (ERT). Consistent with other GHG programs, 1 ERT is equal to
1 metric tonne of C02e.
Verified Carbon Standard (VCS)
Program Background
The VCS program, launched in 2006 as a pilot program, sets a global standard and
provides a framework to verify voluntary GHG emissions reductions. The most recent VCS
Standard v4.0 was released September 19, 2019. VCS covers a diverse range of project
types in 11 sectors using over 40 VCS-approved methodologies (Exhibit 6). VCS also
accepted methodologies developed by the United Nations Framework Convention on
Climate Change Clean Development Mechanism (CDM) and CAR. Unlike the other GHG
programs, VCS provides a framework for project developers to develop new methodologies
or revise existing CDM methodologies.
Mine Methane Protocol
For CMM projects, VCS uses methodology
elements from CDM's approved consolidated
methodology (ACM0008)—"Consolidated
methodology for coal bed methane, CMM and
VAM capture and use for power (electrical or
motive) and heat and/or destruction through
flaring orflameless oxidation." In 2014, ACM0008
was updated and renamed "Abatement of
methane from coal mines," v8.0. VCS accepts all
CMM project types, including pipeline sales, boiler
use, electricity generation, flaring, and VAM.
In March 2009, VCS approved a modification to CDM methodology ACM0008 to accept SMM
projects. This methodology, VMR0001, allows pre-mine drainage wells drilled in advance of
surface (or open-cast) mine highwalls to become eligible once the well comes into contact
with air egress from the mine face. In July 2010, VCS approved another modification to
ACM0008 to include methane recovery and use or destruction from abandoned coal mines.
This methodology, VMR0002, includes AMM, which is defined as "methane extracted from
open or sealed vents, shafts, portals or gob wells at locations where active ventilation has
ceased."
These CDM methodologies use a project-based standard to assess additionality. The CDM
methodology, ACM0008, differs from the other CMM protocols in this document because it
allows for additional emissions reductions to be claimed for projects that displace or avoid
fossil-based energy from other sources such as electricity generation, heat, and vehicle fuel
use. The protocols used by the COP, CAR, and ACR programs, on the other hand, quantify
offsets simply based on the destruction of methane that would otherwise have been
emitted into the atmosphere, and do not consider displacing GHG emissions that are
associated with project-related fossil fuels that otherwise would have been combusted.
GHG Registry
Verra launched its own registry for the VCS program, the Verra Registry, in April 2020 to
list projects, collect project documents, facilitate validation and verification, and issue and
retire offset credits. Previously, it used two international registries: APX Inc. in North
Exhibit 6. Summary of Projects under VCS
To date, VCS has registered a total of
46 CMM/AMM/SMM projects, mostly AMM
projects from Germany whose crediting periods
have expired. As mentioned above, three U.S.-
based VCS projects transitioned VCUs to early
action offset credits for use in the COP.
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America; and IHS Markit in the United States, the United Kingdom, and Asia Pacific regions.
VCS's emissions reduction unit is the VCU. One VCU is equal to 1 metric tonne of CC>2e.
VCS became an approved OPR for the COP in 2016. For more information, visit:
https: //ve rra. o ra / p roi ect/vcs- d roa ra m/.
American Carbon Registry (ACR)
Program Background
Founded in 1996 as a voluntary offset program, ACR was the first private GHG registry in
the United States. ACR originally partnered with Environmental Resources Trust, an
organization that provides carbon technical services, but was eventually acquired by
Winrock International in 2008. As a nonprofit, ACR publishes standards, methodologies,
and protocols, which are all based on International standards Organization 14064 and
sound scientific practices. ACR has developed its own standards and over 20 methodologies
for multiple sectors, such as forestry, livestock, landfill, CMM, and carbon sequestration. In
addition, ACR generally accepts CDM methodologies to the extent that they are found to be
consistent with the ACR Technical Standard. ACR published its most recent Standard v6.0
in July 2019.
Mine Methane Protocol
For CMM projects, ACR uses the Capturing and Destroying Methane from Coal and Trona
Mines in North America methodology published in September 2019. While ACR accepts
projects worldwide, the CMM methodology is a performance-based methodology applicable
to North American mines only. Unlike the CMM methodologies adopted by the COP and
CAR, the ACR methodology uses a more streamlined quantification approach and allows for
CMM pipeline sales as an eligible project type. In addition, AMM projects are not limited by
a maximum volume.
GHG Registry
ACR manages its own registry where it lists projects, collects project documents, facilitates
validation and verification, and issues and retires offset credits. ACR's emissions reduction
unit is the ERT. Consistent with other GHG programs, 1 ERT is equal to 1 metric tonne of
C02e.
ACR became an approved OPR for the COP in 2012. With this approval, ACR had over
10 CMM projects registered in 2019. For more information, visit:
https://americancarbonreQistrv.ora/.
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Exhibit 7. Acronyms and Abbreviations Used in this Document
Acronym
Definition
ACR
American Carbon Registry
AMM
Abandoned mine methane
CARB
California Air Resources Board
CARBOC
CARB Offset Credit
CAR
Climate Action Reserve
CDM
Clean Development Mechanism
CMM
Coal mine methane
CMOP
Coalbed Methane Outreach Program
CChe
Carbon dioxide equivalent
COP
California Compliance Offset Program
CRT
Climate reserve tonne
ERT
Emission reduction ton
GHG
Greenhouse gas
MMC
Mine Methane Capture
OPR
Offset project registry
RGGI
Regional Greenhouse Gas Initiative
ROC
Registry Offset Credit
SMM
Surface mine methane
VAM
Ventilation air methane
VCS
Verra's Verified Carbon Standard
VCU
Voluntary carbon unit
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